Indicator 3.12.2

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System

Water Type

Feed Dependent

Species

Indicator 3.12.2

by Contact on 8 October 2026

Requirement

The UoC shall have an employee grievance mechanism which is accessible, fair and applicable to all employees.

How Do I Interpret This Requirement?

  • A grievance mechanism is a formal complaint process that can be used by employees to resolve a grievance.

  • Based on UN Guiding Principle No. 31, and effective a grievance mechanism must:

    • engender trust among participants

    • be transparent: ensure that users are given clear information about what is happening

    • be fair: ensure that users have access to sources of information and expertise necessary to engage in a grievance process

    • be predictable: ensure that users understand the process, how long it takes and what the outcomes can be

    • be accessible: ensure that users have been informed about it and can use it

    • be rights-based: ensure that outcomes and remedies are compatible with international human rights

    • be based on dialogue and engagement, ensuring that stakeholders are consulted and included in the process

    • be a source for continuous learning, analysing individual complaints to help prevent other grievances.

  • Mechanisms for submitting grievances are best determined together with employee representatives and can include:

    • in-person meetings

    • dedicated telephone numbers

    • email addresses

    • instant messaging or other online submission mechanisms

    • letters or written notes

    • a suggestion box

    • via employee representatives, trade unions, and worker associations

    • worker voice tools to conduct anonymous worker surveys.

  • For a grievance mechanism to be accessible for employees they must understand:

    • their labour rights (Criterion 3.1)

    • rights related to other workplace issues, such as health and safety regulations (Criterion 3.5)

    • how the grievance mechanism functions and what kinds of issues may be brought to the grievance mechanism (see also 3.12.3).

  • Foreign migrant workers may be given the option to raise issues:

    • internally with the UoC using the same channels open to other employees

    • with the local Consular Office of the Labour Attaché for their country in the country where the UoC is located

    • websites or Facebook pages of the Consulate or Embassy where migrant workers can raise grievances.

  • An effective grievance process will incorporate elements of the following steps at a minimum (adapted from Rainforest Alliance’s Grievance Guidance):

    • Step 1: Receive and acknowledge grievance complaint

    • Step 2: Take immediate action on human rights or hazardous issues (see Appendix 10 for the Remediation Procedure)

    • Step 3: Review the grievance complaint to check if it is admissible.

      • if it is inadmissible, this is communicated along with the reason, to the person who brought the grievance.

    • an inadmissible complaint is one that is unrelated to the activities or location of the UoC.

    • Step 4: Investigate the grievance complaint to establish what happened, maintaining confidentiality.

    • for complex issues or where there are conflicts of interest, external experts may be brought in to support.

      • Step 5: Communicate findings to the person who brought the grievance.

      • Step 6: Agree on a remediation plan with the person who brought the grievance.

        • for complex issues, external arbitration and external remediation support including NGOs or rights experts may be brought in.

    • Step 7: Provide an opportunity for an appeals process, if agreement cannot be reached.

    • Step 8: Implement and monitor the remediation plan.

      • Step 9: Communicate the progress of the remediation to the person who brought the grievance and to any relevant stakeholders when confidentiality is not a concern.

      • Step 10: Engage in continuous improvement.

| > Example grievance  | Example resolution |

| > My wages are always paid 4 or 5 days late, sometimes even more than a week late. This makes it difficult to plan when to pay my bills and how to manage my finances. | 1. Member of staff hearing the grievance ensures that the employee understands that their complaint is confidential.  |

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| | 2. Ensure that the employee has received their latest wages.  |

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| | 3. Interview other employees to understand if anyone else is experiencing the same issue.  |

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| | 4. Examination of the wage payment system to understand why there are delays.  |

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| | 5. Any changes necessary are implemented.  |

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| | 6. Next month, the member of staff who is working on the grievance checks with the employee about the date they received their wages.  |

| > I keep being asked to go out onto the feed barge without being provided with a lifejacket. | 1. Member of staff hearing the grievance ensures that the employee understands that their complaint is confidential.  |

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| | 2. Interview other employees to understand if anyone else is experiencing the same issue.  |

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| | 3. Check the availability of life jackets and ensure that there is a sufficient number available, that they are in good working condition and that they are kept in an accessible location.  |

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| | 4. Add some signs to remind workers and management that life jackets are essential for going onto the feed barge.  |

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| | 5. Follow up with the employee after a few weeks to find out if the situation has improved.  |

Evidence of Implementation

  • grievance policy or procedure

  • employee survey results

  • employee notices and notice boards

  • employee handbook

  • records from grievance procedures and their outcomes

  • meeting minutes.

Auditors Should Confirm

  • if the grievance procedure provides employees with clearly written and understandable instructions on how to report grievances using different methods that involve formal, informal and anonymous reporting;

  • if the grievance procedure applies to and is accessible to all employees, including full-time, permanent, contract, seasonal, migrant (domestic and foreign) and temporary employees.

Useful Resources